Tax Residency Under Domestic Laws

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Tax Residency Under Domestic Laws

Author : Nuhu Musa Idris
Publisher : Eliva Press
ISBN 13 : 9789994982264
Total Pages : 0 pages
Book Rating : 4.9/5 (822 download)

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Book Synopsis Tax Residency Under Domestic Laws by : Nuhu Musa Idris

Download or read book Tax Residency Under Domestic Laws written by Nuhu Musa Idris and published by Eliva Press. This book was released on 2022-08-28 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author demonstrates that in exercising income tax jurisdiction, the state can choose to have a link with the personality of the income-earner within its territory whether or not the income was derived from a source within its territory (residence-based taxation). No universal rules for determining the tax residence of a person (either natural or juristic) for tax purposes apply in all circumstances. Thus, the states have different definitional rules of residence as contained in their respective income tax legislation and as interpreted by their courts. The global economic integration makes taxpayers move freely and exploit ambiguity created by the divergence of the definition of the tax jurisdiction between the States. The book explores the possibility of achieving cooperation amongst the States in delimiting the scope of their substantive and enforcement tax jurisdiction without losing their sovereignty. The cooperation envisioned by this research is a departure from the traditional approach, where the focal point of achieving cooperation is either bilateral or multilateral tax treaties. The author argues that the cooperation could be achieved through comparative analysis of the definition rule to ascertain the level of convergence and divergence and how they could extend mutual respect for each other's tax sovereignty and balance their interests against that of the taxpayers in defining the tax residence. The book uses Nigeria and South Africa as a case study. Nigeria has adopted the residence-based system at the inception of its income tax system, while South Africa initially adopted the source-base system but later switched to the residence-based system.

U.S. Tax Guide for Aliens

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.:/5 (13 download)

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Book Synopsis U.S. Tax Guide for Aliens by : United States. Internal Revenue Service

Download or read book U.S. Tax Guide for Aliens written by United States. Internal Revenue Service and published by . This book was released on 1985 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Residence of Individuals Under Tax Treaties and EC Law

Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087220758
Total Pages : 709 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Residence of Individuals Under Tax Treaties and EC Law by : Guglielmo Maisto

Download or read book Residence of Individuals Under Tax Treaties and EC Law written by Guglielmo Maisto and published by IBFD. This book was released on 2010 with total page 709 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.

U.S. Tax Treaties

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 28 pages
Book Rating : 4.3/5 (126 download)

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Book Synopsis U.S. Tax Treaties by : United States. Internal Revenue Service

Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:

United States Code

Author : United States
Publisher :
ISBN 13 :
Total Pages : 1716 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis United States Code by : United States

Download or read book United States Code written by United States and published by . This book was released on 2001 with total page 1716 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Corporate Tax Residence and Mobility

Author : Edoardo Traversa
Publisher :
ISBN 13 : 9789087224516
Total Pages : 764 pages
Book Rating : 4.2/5 (245 download)

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Book Synopsis Corporate Tax Residence and Mobility by : Edoardo Traversa

Download or read book Corporate Tax Residence and Mobility written by Edoardo Traversa and published by . This book was released on 2018 with total page 764 pages. Available in PDF, EPUB and Kindle. Book excerpt: The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject resident corporate taxpayers to full tax liability, usually on a worldwide basis. In tax treaties, residence plays a fundamental role in the allocation of taxing powers between states. Moreover, within the European Union, it gives access to the legal protection granted to companies by internal market rules, whether contained in EU treaties (fundamental freedoms) or in tax directives. Today, however, the globalization and the digitalization of the economy are putting residence under heavy pressure. Within multinational enterprises, the geographical dislocation of the functions performed by people and entities within the multinational group makes it harder to identify a central place of decision or management in cases where this place is not the same as the place where the company was incorporated. Moreover, tax planning strategies involving location or the transfer of residence to low-tax jurisdictions have come under the spotlight of international organizations, such as the OECD and the European Union. Against this background, this book examines the notion of residence from a comparative, EU and international law perspective. It is divided into two parts. Part one comprises a general introductory report, as well as five thematic reports on key present and future issues concerning the tax residence of companies. Part two comprises the national reports of 14 EU Member States and 6 non-EU Member States (Norway, Russia, Serbia, Turkey, Ukraine and the United States). Those reports contain an extensive analysis of the definition and function of corporate tax residence on the basis of a questionnaire (which is included as an appendix in this book). With contributions from renowned academics from Europe and beyond, this book offers an insightful and multifaceted perspective on a fundamental concept of domestic and international taxation.

Residence of Companies Under Tax Treaties and EC Law

Author : Guglielmo Maisto (jurist.)
Publisher : IBFD
ISBN 13 : 9087220561
Total Pages : 969 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Residence of Companies Under Tax Treaties and EC Law by : Guglielmo Maisto (jurist.)

Download or read book Residence of Companies Under Tax Treaties and EC Law written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2009 with total page 969 pages. Available in PDF, EPUB and Kindle. Book excerpt: Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.

Tax Treaty Residence of Entities

Author : Jan Gooijer
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403513055
Total Pages : 383 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Tax Treaty Residence of Entities by : Jan Gooijer

Download or read book Tax Treaty Residence of Entities written by Jan Gooijer and published by Kluwer Law International B.V.. This book was released on 2019-09-13 with total page 383 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.

Internal Revenue Cumulative Bulletin

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 1088 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Internal Revenue Cumulative Bulletin by : United States. Internal Revenue Service

Download or read book Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and published by . This book was released on 2004 with total page 1088 pages. Available in PDF, EPUB and Kindle. Book excerpt:

International Commercial Tax

Author : Peter Harris
Publisher : Cambridge University Press
ISBN 13 : 9780521853118
Total Pages : 520 pages
Book Rating : 4.8/5 (531 download)

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Book Synopsis International Commercial Tax by : Peter Harris

Download or read book International Commercial Tax written by Peter Harris and published by Cambridge University Press. This book was released on 2010-07-22 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.

The Canadian Snowbird Guide

Author : Douglas Gray
Publisher : John Wiley & Sons
ISBN 13 : 0470739428
Total Pages : 293 pages
Book Rating : 4.4/5 (77 download)

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Book Synopsis The Canadian Snowbird Guide by : Douglas Gray

Download or read book The Canadian Snowbird Guide written by Douglas Gray and published by John Wiley & Sons. This book was released on 2009-12-31 with total page 293 pages. Available in PDF, EPUB and Kindle. Book excerpt: Each year, more than a million Canadians, affectionately dubbed "Snowbirds," migrate to southern climes to enjoy warm weather and sandy beaches. The strong Canadian dollar is making the trip more affordable and attractive than ever. But post-9/11, Canadians face tighter security, higher health costs, and higher fuel costs when traveling to the US. Canadians must budget accordingly. Especially for first-timers, how can they properly plan their trip to ensure a worry-free time away from home? Among the topics this book includes are: the Snowbird lifestyle; financial planning; what documents you need to enter the US; what types of insurance and coverage are recommended; ensuring you have an up-to-date will; how US tax law applies to Canadians if money is earned or property sold; snowbirding in Mexico and Costa Rica; plus FAQs, checklists, and sources of further information.

The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States

Author : Stef Weeghel
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041107371
Total Pages : 302 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States by : Stef Weeghel

Download or read book The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States written by Stef Weeghel and published by Kluwer Law International B.V.. This book was released on 1998-03-27 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With particular reference to the Netherlands and the United States."--T.p.

How Money Walks - How $2 Trillion Moved Between the States, and Why It Matters

Author : Travis H. Brown
Publisher : How Money Walks
ISBN 13 : 0988740117
Total Pages : 153 pages
Book Rating : 4.9/5 (887 download)

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Book Synopsis How Money Walks - How $2 Trillion Moved Between the States, and Why It Matters by : Travis H. Brown

Download or read book How Money Walks - How $2 Trillion Moved Between the States, and Why It Matters written by Travis H. Brown and published by How Money Walks. This book was released on 2013 with total page 153 pages. Available in PDF, EPUB and Kindle. Book excerpt: Between 1995 and 2010, millions of Americans moved between the states, taking with them over $2 trillion in adjusted gross incomes. Two trillion dollars is equivalent to the GDP of California, the ninth largest in the world. It’s a lot of money. Some states, like Florida, saw tremendous gains ($86.4 billion), while others, like New York, experienced massive losses ($58.6 billion). People moved, and they took their working wealth with them. The question is, why? Why did Americans move so much of their income from state to state? Which states benefitted and which states suffered? And why does it matter? Using official statistics from the IRS, How Money Walks explores the hows, whys, and impact of this massive movement of American working wealth. Consider these facts. Between 1995 and 2010: The nine states with no personal income taxes gained $146.2 billion in working wealth The nine states with the highest personal income tax rates lost $107.4 billion The 10 states with the lowest per capita state-local tax burdens gained $69.9 billion The 10 states with the highest per capita state-local tax burdens lost $139 billion Money—and people—moved from high-tax states to low-tax ones. And the tax that seemed to matter the most? The personal income tax. The states with no income taxes gained the greatest wealth, while the states with the highest income taxes lost the most. Why does this matter? Because the robust presence of working wealth is the leading indicator of economic health. The states that gained working wealth are growing and thriving. The states that lost working wealth lost their most precious cargo—their tax base—and the consequences are dire: stagnation, deterioration, an economic death spiral as they continue to raise taxes and lose people, businesses, and working wealth. The numbers don't lie. ___________________ “When I read How Money Walks, I thought, ‘It’s about time.’ Finally, we have a book that addresses one of our nation’s most critical (yet rarely discussed) fiscal issues: the migration of working wealth as a direct result of personal income tax rates. Brown’s book paints a clear portrait of where money goes and why. How Money Walks should be required reading for anyone who wants to understand why some states struggle to retain people and businesses while others welcome billions of new dollars each year.” Dr. Arthur Laffer Founder and chairman, Laffer Associates and Laffer Investments Former economic advisor to President Ronald Reagan

Individual Tax Residence

Author : Setu Kamal
Publisher : Sweet & Maxwell
ISBN 13 : 0414045912
Total Pages : 382 pages
Book Rating : 4.4/5 (14 download)

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Book Synopsis Individual Tax Residence by : Setu Kamal

Download or read book Individual Tax Residence written by Setu Kamal and published by Sweet & Maxwell. This book was released on 2011 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the law relating to individual tax residence. It summarises the rules in statute and common law (including the topical recent high-profile cases). It includes commentary and analysis of this important topic and questions commonly held views as to what steps need to be taken to achieve non-residence

Internal Revenue Bulletin

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 1072 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Internal Revenue Bulletin by : United States. Internal Revenue Service

Download or read book Internal Revenue Bulletin written by United States. Internal Revenue Service and published by . This book was released on 1991 with total page 1072 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Individual retirement arrangements (IRAs)

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 284 pages
Book Rating : 4.:/5 (334 download)

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Book Synopsis Individual retirement arrangements (IRAs) by : United States. Internal Revenue Service

Download or read book Individual retirement arrangements (IRAs) written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt:

International Tax Policy and Double Tax Treaties

Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes

Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.